Great write up, Kristian. Thank's for doing the heavy lifting
Craig Demanty, CEO unWired Broadband Inc iPhone On Jun 14, 2017, at 3:01 PM, Kristian Hoffmann <[email protected]<mailto:[email protected]>> wrote: Latest draft attached. This will be the final unless I get other feedback. Thanks, -Kristian On 06/14/2017 01:14 PM, Kristian Hoffmann wrote: Hi, Attached is my draft for the informal comments due today. You won't hurt my feelings, so please fire away with comments/suggestions/revisions. I'll plan on having the final version put together (hopefully with your feedback) at 4:00pm today, and send it off shortly thereafter. If you would like to modify this, add your own back story to the second paragraph, etc., feel free to do so. I just ask that you send me a copy or at least let me know that you did send your own version to the CPUC. Or, if you reply on/off-list with your name, business name, and address, I'll add you to the signature line when I send mine in. Thanks, -Kristian On 06/13/2017 04:39 PM, Kristian Hoffmann wrote: Hi, The comments are due tomorrow. I'll try to post a draft around noon tomorrow before I send it to the CPUC. From the feedback I've gotten, and having time to ponder it, I think a reasonable compromise might be to submit deployment data at the census block level. This would be similar to the FCC Form 477 format, except more granular. Most OSS/billing/mapping providers that already support FCC Form 477 should be able to accommodate this difference without significant trouble. This change would align the data with the current CASF application process. Note that there was some discussion about requiring parcel numbers instead of census blocks for CASF applications, which would possibly (likely?) extend to their mapping requirements down the road. The caveat here is that the CPUC will likely not "validate" a census block marked as served unless it also has subscriber data that shows customers in the same block. I'm thinking of proposing that they adopt a less black/white validation process. Instead of invalidating a census block as unserved by a single provider based on if they have subscribers in that block, they could aggregate all subscribers by technology (e.g. fixed wireless) and report that as a percentage. So you have census block 06099123456789 that is served by fixed wireless providers X, Y and Z that collectively serve 80 of 100 households. That block should be less desirable from a CASF application vetting standpoint than one that, say, only has 5 out of 100 households served. Thoughts? And if you haven't already, please take a minute to fill out the survey. As Will Ferrell playing Harry Caray said... "It's a simple question. A baby could answer it!!!" https://goo.gl/forms/Zsu06Jake0aEF68H2 Your reward for completing the survey... https://www.youtube.com/watch?v=8Cs5O0PEnYs Thanks, -Kristian On 05/31/2017 12:06 PM, Kristian Hoffmann wrote: Hi, I'll try to summarize the meeting, but there are a few action items that I'd like everyone to seriously consider. First, a couple of bullet points to be aware of: - There were several parties that suggested (and felt strongly about) only accepting CASF grant challenges from providers who have already filed Form 477 data in the past. - There were similar feelings towards accepting late challenges. - Current availability is measured at the census block level. There were suggestions (and some agreement) that this should perhaps be done at the parcel level (house by house). - I pointed out the contradiction of counting households served by fixed wireless as "unserved", but also approving CASF grants to serve "unserved" areas with fixed wireless. Wouldn't they still be "unserved?" The staff acknowledged the contradiction, and asked for suggestions to improve the situation. In short, fixed wireless isn't being taken seriously as a viable long-term option for broadband services. The CPUC staff acknowledges the benefit it provides now, and even the possibility of being a good option in the future. However, the other industry players chuckled at the mention of fixed wireless. I think the disconnect with the CPUC comes from lack of cooperation on our part. They're a data-driven organization. They have to back up their decisions with facts, studies, reports, etc. If we're not giving them good data, then we don't exist. That said, I'm not a fan of the latest format of their data request for fixed wireless (locations of all antennas, radio make/model, etc.), though I do understand why they've gone that direction. A lot of WISPs were providing large hand-drawn coverage maps that just aren't specific enough. So where do we go from here? My intention is to come up with some kind of compromise so that we can get the CPUC the data they need to substantiate the fixed wireless industry, what it has already done, and what it can do in the future. Back when the original request for data came from the NTIA, there weren't a lot of options. Now, there are at least a couple of reasonably priced commercial options (separate services, and integrated into billing software) for generating coverage maps and creating a list of served census blocks that should coincide with the CPUC's underlying requirements. My first thought would be to approach a neutral vendor like towercoverage.com<http://towercoverage.com>, and work with them so that they could generate a dataset that would be acceptable to the CPUC. I have no bias towards towercoverage.com<http://towercoverage.com>, just that they already provide this service for filing the FCC Form 477 data. I would also have to work with the CPUC to come up with a format that they would be okay with, though I believe the mobile wireless format is close enough, or could work with minor modifications. I created a short survey (linked below) to gauge the interest level, get feedback, etc. I plan on filling comments regardless of the response level, but I would much rather the comments be based on the feedback from other operators, and not just my own. https://goo.gl/forms/Zsu06Jake0aEF68H2 You're also welcome to send your own informal comments as instructed in the attached email. However, I think we would benefit from multiple operators sending a consistent message. If there's a good enough response, I'll create a template response that we can send individually or signed as a group. Thanks for your time, -Kristian -------- Forwarded Message -------- Subject: CASF Staff Draft Proposal Comment Period Date: Sat, 27 May 2017 00:29:53 +0000 From: TD_AR <[email protected]><mailto:[email protected]> To: '[email protected]<mailto:[email protected]>' <[email protected]><mailto:[email protected]> STATE OF CALIFORNIA Edmund G. Brown Jr., Governor <image001.png> PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3298 May 26, 2017 To: Parties on the CASF Distribution (Service) List: Thank you to those who participated in the CASF workshop yesterday. I extend the offer to anyone wishing to provide written comments on the staff proposal to do so by end of day, June 14th, directly to [email protected]<mailto:[email protected]> As I explained during the workshop yesterday, these written comments are part of a staff informal inquiry. Because this is an informal effort, there is no requirement to serve written comments to the CASF distribution / service list. I intend to present a refined staff proposal to the assigned ALJ and Commissioner of the existing CASF proceeding OIR 12-10-012. Should the proceeding be expanded, or the Commission wishes to initiate a separate proceeding, you will have the opportunity to file formal comments as part of such proceeding before any rules are changed. Thanks again for your thoughtful suggestion for improving the CASF program. Sincerely, Robert Wullenjohn Manager, Broadband, Video and Market Branch Communications Division, CPUC _______________________________________________ California mailing list [email protected]<mailto:[email protected]> http://lists.wispa.org/mailman/listinfo/california _______________________________________________ California mailing list [email protected]<mailto:[email protected]> http://lists.wispa.org/mailman/listinfo/california _______________________________________________ California mailing list [email protected]<mailto:[email protected]> http://lists.wispa.org/mailman/listinfo/california <Informal comments 20170614-02.pdf> _______________________________________________ California mailing list [email protected]<mailto:[email protected]> http://lists.wispa.org/mailman/listinfo/california
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